This privacy policy clarifies the nature, scope and purpose of the processing of personal data (hereafter “Data”) within our online presence and the related websites, functions and contents as well as external online presences, e.g. our social media profiles (hereafter collectively referred to as “online presence”). With regard to the terminology used, e.g. “Processing” or “Controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Purpose of processing

Terms used

“Personal data” is any information that relates to an identified or identifiable natural person (hereinafter referred to as “data subject”); natural persons are considered as identifiable, if they can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, which are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

“Processing” means any process performed with or without the aid of automated procedures associated with personal data. The term covers a wide range and covers virtually every usage of such data.

“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data can not be assigned to an identified or identifiable natural person.

“Controller” means the natural or legal person, public authority, agency or other entity that alone or jointly with others decides on the purposes and means of processing personal data.

“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis is mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing and fulfillment of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) lit. d GDPR serves as legal basis.

Safety measures

We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the respective likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the rights of data subjects, data deletion and reaction to data risks. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).

Collaboration with processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit to or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if transmission of the data to a third party, like a payment service, is required to fulfill the contract, according to Art. 6 (1) (b) GDPR), you have consented to a legal obligation or based on our legitimate interests (e.g. the use of agents, webhosters, etc.).

If we commission third parties to process data on the basis of a so-called “Data Processing Agreement”, this is done on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. Meaning that the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or in compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of data subjects

You have the right to ask for confirmation as to whether your personal data is being processed and for information about this data as well as a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR you have the right to demand the completion of your personal data or the rectification of incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that your personal data be deleted immediately or, alternatively, to require a restriction of the processing in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be delivered to you in accordance with Art. 20 GDPR and request their transmission to other controllers.

Furthermore according to Art. 77 GDPR you have the right to file a complaint with the responsible supervisory authority.

Right to withdraw consent

You have the right to withdraw granted consent in accordance with. Art. 7 (3) GDPR with effect for the future.

Right to object

You can object to further processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies

“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies, also called “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart are stored in an online store or the login status. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for reach measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online service (otherwise, if it is only their own cookies, they are called “first-party cookies”).

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies stored on their computer, they are asked to disable the option in their browser’s settings. Saved cookies can be deleted in the settings of the browser. The exclusion of cookies can lead to functional restrictions of this online service.

Deletion of data

The data processed by us are deleted or restricted in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any storage requirements required by law. If the data is not deleted because it is required for other and legitimate purposes, its processing will be restricted, i.e. the data is locked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax law related reasons.

Contractual services

We process the data of our contractual partners and prospects as well as other clients (uniformly referred to as “contractual partners”) in accordance with Art. 6 (1) lit. b. GDPR in order to provide you with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship.

Generally we do not process special categories of personal data, unless they are part of a contractual processing.

We process data which are necessary for the establishment and fulfillment of the contractual services and point out the necessity of this processing, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us within the context of an order, we act in accordance with the instructions of the client as well as the legal requirements.

The data will be deleted if the data is no longer required for the fulfillment of contractual or statutory duties and for the handling of any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory storage obligations apply.

We process data in the context of administrative tasks, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of provisioning our contractual services. The processing principles are Art. 6 (1) lit. c. GDPR, Art. 6 (1) lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided for these processing activities.

We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this mostly company-related data permanently.

Business analysis and market research

In order to run our business economically, to be able to recognize market trends, customer and user requirements, we analyze the data we have on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 (1) lit. f. GDPR, whereby the persons affected include customers, prospects, business partners, visitors and users of the online presence.

The analysis is carried out for the purpose of business analysis, marketing and market research. The analysis serves us to increase the user-friendliness, the optimization of our services and business economics. The analysis is for us alone and will not be disclosed externally unless they are anonymised and aggregated.

If the analysis or profiles are personal data, they will be deleted or anonymised upon termination of the user accounts, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analysis and general trend determination are created anonymously if possible.

Privacy policy for the application process

We process applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfill our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 (1) lit. b. GDPR, or Art. 6 (1) lit. f. GDPR if the data processing e.g. is required for us in the context of legal proceedings (in Germany, § 26 BDSG applies additionally).

The application process requires applicants to provide us with the applicant data. The mandatory applicant data are marked, if we offer an online form, otherwise result from the job descriptions and basically include the details of the person, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and the certificates. In addition, applicants can voluntarily provide us with additional information.

By submitting the application to us, the applicants agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set forth in this privacy policy.

Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b GDPR (e.g., health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. a GDPR (for example health data, if necessary for the profession).

If provided, applicants can submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us according to the state of the art.
Furthermore, applicants can send us their applications via email. However, please note that emails are generally not sent in encrypted form and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Instead of applying via the online form and email, applicants still have the opportunity to send us the application by post.

The data provided by the applicants may be further processed by us in the event of a successful application for employment purposes. Otherwise, if the application for a job offer is unsuccessful, the applicants’ data will be deleted or destroyed. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to at any time.

The deletion is performed, subject to a legitimate cancellation of the candidate, after the expiration of a period of six months, so that we can answer any follow-up questions to the application and meet our obligations under the “Allgemeines Gleichbehandlungsgesetz” (AGG, german law regarding equal treatment). Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

Contacting Us (CRM System)

When contacting us (for example, by contact form, email, telephone, via social media, or providing a business card) the user data is used in order to process the contact request in accordance with. Art. 6 (1) lit. b GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or comparable system.

We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, legal archiving obligations apply.

Hosting

The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, email, security and technical maintenance services we use to operate this online presence.

Collection of access data and log files

We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f. GDPR data on each access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from deletion until final clarification of the incident.

Links external webpages

All links to external webpages do not set a so called “referrer”. This means that the visited site will not know from which site it was called.

Google Analytics

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online service within the meaning of Art. 6 (1) lit. GDPR), we use Google Analytics, a web analytics service provided by Google LLC (“Google”). While doing so we do not use any (tracking) cookies by Google.

Google will use this information on our behalf to evaluate the use of our online service by users, to compile reports on the activities within this online service and to provide us with further services related to the use of this online service and related usage. Pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

The IP address submitted by the user’s browser will not be merged with other data by Google. Users may also prevent Google from collecting data related to their use of the online presence and Google’s processing of such data by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

The personal data of users will be deleted or anonymised after 14 months.

Online presence in social media

We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users and to inform them about our services. When using these networks and platforms, the terms and conditions and the data processing guidelines of the respective service applies.

Unless otherwise stated in our privacy policy, we process users’ data as long as they communicate with us within social networks and platforms, e.g. write posts on our online presence or send us messages.

Integration of services and contents of third parties

Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online presence within the meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to embed their content and services, such as videos or fonts (collectively referred to as “content”).

This always requires that the third-party providers of this content receive the IP address of the users, since they could not send the content to their browser otherwise. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online presence.